Interpretation ID: aiam1066
Young Windows
Inc.
Brook and Colwell Roads
Conshohocken
PA 19428;
Dear Mrs. Cook: This is in reply to your letter of February 20, 1973, requestin clarification of the certification and labeling requirements of Motor Vehicle Safety Standard No. 205, 'Glazing Materials', for persons who cut sections of glazing materials. You state your understanding is that such persons should add to the cut piece the DOT symbol and the manufacturer's code mark used on the larger piece from which the smaller piece was cut. Your understanding of these requirements is not correct. The labeling requirements of Standard No. 205 were most recently amended on November 11, 1972 (37 FR 24035, copy enclosed). These amendments become effective April 1, 1973. They require a person who cuts glazing material to mark it in accordance with section 6 of ANS Z26. This does *not* include the DOT symbol and the mark of the manufacturer of the larger sheet, and these items should *not* be included by persons who only cut the material. That person must also certify the material in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act (15 USC 1403). One method by which this can be done is to affix a removable label to the glazing material which states that it conforms to the Federal safety standard.; You ask how the 'AS12' and 'AS13' marking should be affixed. The 'AS designation is part of the labeling required by section 6 of ANS Z26, and it should be applied in the manner that the other labeling items of that section are applied. We understand etching is the method ordinarily used, and it is appropriate.; Sincerely, Richard B. Dyson, Assistant Chief Counsel